{"cached_at":"2026-10-16T10:41:32.634607+00:00","cl_docket_id":"69005981","docket":{"resource_uri":"https://www.courtlistener.com/api/rest/v4/dockets/69005981/","id":69005981,"court":"https://www.courtlistener.com/api/rest/v4/courts/nywd/","court_id":"nywd","original_court_info":null,"idb_data":null,"clusters":[],"audio_files":[],"assigned_to":"https://www.courtlistener.com/api/rest/v4/people/1174/","referred_to":null,"bankruptcy_information":null,"absolute_url":"/docket/69005981/christman-v-terawulf-inc/","date_created":"2024-08-01T07:57:55.181003-07:00","date_modified":"2025-05-17T08:52:12.011995-07:00","source":1,"appeal_from_str":"","assigned_to_str":"Frank P. Geraci, Jr.","referred_to_str":"","panel_str":"","date_last_index":"2024-08-01T07:57:55.367626-07:00","date_cert_granted":null,"date_cert_denied":null,"date_argued":null,"date_reargued":null,"date_reargument_denied":null,"date_filed":"2024-07-31","date_terminated":"2024-12-30","date_last_filing":"2024-12-30","case_name_short":"Christman","case_name":"Christman v. TeraWulf Inc.","case_name_full":"","slug":"christman-v-terawulf-inc","docket_number":"6:24-cv-06473","docket_number_core":"2406473","docket_number_raw":"6:24-cv-06473","docket_number_source":0,"federal_dn_office_code":"6","federal_dn_case_type":"cv","federal_dn_judge_initials_assigned":"FPG","federal_dn_judge_initials_referred":"","federal_defendant_number":null,"pacer_case_id":"151896","cause":"","nature_of_suit":"","jury_demand":"","jurisdiction_type":"","appellate_fee_status":"","appellate_case_type_information":"","mdl_status":"","filepath_ia":"","filepath_ia_json":"","ia_upload_failure_count":null,"ia_needs_upload":true,"ia_date_first_change":"2024-08-01T07:57:55.177944-07:00","date_blocked":null,"blocked":false,"appeal_from":null,"parent_docket":null,"tags":[],"panel":[]},"parties":[],"entries":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/398152840/","id":398152840,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/69005981/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/407338197/","id":407338197,"tags":[],"absolute_url":"/docket/69005981/1/christman-v-terawulf-inc/","date_created":"2024-08-01T07:57:55.302522-07:00","date_modified":"2024-08-02T02:08:05.210592-07:00","sha1":"71795ce8b4f11f0600259a4614e5481e73e25e63","page_count":13,"file_size":619531,"filepath_local":"recap/gov.uscourts.nywd.151896/gov.uscourts.nywd.151896.1.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nywd.151896/gov.uscourts.nywd.151896.1.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"            Case 6:24-cv-06473 Document 1 Filed 07/31/24 Page 1 of 13\n\n\n\n\nUNITED STATES DISTRICT COURT\nWESTERN DISTRICT OF NEW YORK\n JOSHUA CHRISTMAN,\n on behalf of himself and all other employees similarly\n situated,\n                                                                 CLASS ACTION COMPLAINT\n                                            Plaintiff,\n             v.                                                  AND DEMAND FOR JURY TRIAL\n\n TERAWULF INC. and BEOWULF E&D (NY) INC.\n                                                                              Civil Action No.\n                                           Defendants.                           No. 24-cv-\n\n\n\n       Plaintiff Joshua Christman (\u201cPlaintiff\u201d), on behalf of himself and all other persons similarly\n\nsituated, (collectively \u201cPlaintiffs\u201d), through his attorney Cordello Law PLLC brings this class\n\naction complaint against Defendants TeraWulf, Inc. (\u201cTeraWulf\u201d) and Beowulf E&D (NY) Inc.\n\n(\u201cBeowulf\u201d) collectively referred to as \u201cDefendants\u201d. Additionally, Joshua Christman brings this\n\nproceeding individually to redress the deprivation of rights secured for damages as a result of\n\nDefendants\u2019 unlawful termination of his employment.\n\n                                 NATURE OF THE ACTION\n\n       1. This lawsuit seeks to recover untimely wage compensation, injunctive relief,\n\ndeclaratory relief and other damages for Plaintiff and similar hourly workers including but not\n\nlimited to: electricians, techs, operations and maintenance workers, (collectively \u201cManual\n\nWorkers\u201d) who work or have worked as Manual Workers for Defendants in New York State.\n\n       2. Plaintiff Joshua Christman worked as a Data Center Operator at Defendants\u2019 Lake\n\nMariner location in Barker, New York. Throughout his employment, Plaintiff and all other Manual\n\nWorkers at Lake Mariner spent more than 25% of their time performing duties that were physical\n\nin nature and were therefore \u201cmanual workers\u201d under the New York Labor Law (\u201cNYLL\u201d).\n\f            Case 6:24-cv-06473 Document 1 Filed 07/31/24 Page 2 of 13\n\n\n\n\n       3. In 1967, the New York State legislature amended NYLL \u00a7 198 to impose \u201cstronger\n\nactions\u201d in the form of liquidated damages to compel employers to comply with the requirements\n\nof Article 6 of the NYLL, including the frequency of payment requirements set forth in Section\n\n191 of the NYLL. These \u201cstronger actions\u201d serve to \u201ccompensate the employee for the loss of the\n\nuse of money to which he [or she] was entitled,\u201d as is the case with late wage payments, because\n\nan employee loses \u201cthe use of money [when] he or she is never paid, partially paid, or paid late.\u201d\n\nVega v. CM & Assocs. Constr. Mgt., 175 A.D.3d 1144, 1146 n. 2 (1st Dep\u2019t 2019)(citation omitted).\n\nThis concept is not new. For decades, the United States Supreme Court has likewise interpreted\n\nthe Fair Labor Standards Act, 29 U.S.C. \u00a7 201 et seq. (\u201cFLSA\u201d), on which the NYLL is based, as\n\nentitling employees to recover liquidated damages \u201cregardless of whether an employee has been\n\npaid wages owed before the commencement of the action.\u201d Id. (quoting Brooklyn Savings Bank v.\n\nO\u2019Neil, 324 U.S. 697, 707 (1945)).\n\n       4. Defendants violated Section 191 of the NYLL by paying its Manual Workers\u2019 wages on\n\na biweekly basis. As \u201cmanual workers\u201d within the meaning of the NYLL, they should have been\n\npaid \u201cweekly and not later than seven calendar days after the end of the week the[ir] wages are\n\nearned.\u201d NYLL \u00a7 191(1)(a)(i).\n\n       5. In this regard, Defendants have failed to provide timely wages to Plaintiff and all other\n\nManual Workers.\n\n       6. Headquartered in Easton, Maryland, Defendants own and operate a bit coin mining\n\noperation in New York State \u2013 Lake Mariner located in Barker, New York.\n\n       7. At all relevant times Defendants have compensated Plaintiff and all other Manual\n\nWorkers on a bi-weekly basis.\n\n       8. Plaintiff brings this action on behalf of himself and all other similar Manual Workers in\n\n\n\n                                               -2-\n\f              Case 6:24-cv-06473 Document 1 Filed 07/31/24 Page 3 of 13\n\n\n\n\nNew York pursuant to Federal Rule of Civil Procedure 23 (\u201cRule 23\u201d) to remedy violations of the\n\nNYLL, Article 6, \u00a7 191.\n\n        9. Additionally, this is a proceeding for declaratory relief, injunctive relief and monetary\n\ndamages to redress the deprivation of rights secured to Plaintiff, Joshua Christman under NYLL \u00a7\n\n740, for damages as a result of Defendants\u2019 unlawful termination of Mr. Christman.\n\n        10. This action seeks damages and equitable relief, costs, expenses, expert witness and\n\nattorneys\u2019 fees; restitution to Mr. Christman of all rights, privileges; declaratory and injunctive\n\nrelief, including Mr. Christman\u2019s reinstatement to his former position, consequential,\n\ncompensatory, punitive damages and a civil penalty of $10,000.\n\n                                  JURISDICTION AND VENUE\n\n        11. This Court has subject matter jurisdiction pursuant to 28 U.S.C. \u00a71332 because there\n\nis diversity of citizenship between Plaintiff and Defendants and the amount in controversy exceeds\n\n$75,000.00.\n\n        12. Venue is proper in the United States District Court for the Western District of New\n\nYork pursuant to 28 U.S.C. \u00a71391(b)(2) because a substantial part of the events or commissions\n\ngiving rise to the claims occurred in this district.\n\n        13.    Defendants operate and do business in New York State and are subject to personal\n\njurisdiction in this Court.\n\n        14.    Plaintiff earned on average $64,000 annually ($30.90/hour) and his claim for\n\nliquidated damages pursuant to NYLL \u00a7 191 exceeds his annual compensation based on his length\n\nof employment with Defendants. In addition, Plaintiff\u2019s claim for retaliatory termination pursuant\n\nto NYLL \u00a7 740 includes back pay, front pay, lost fringe benefits, punitive damages and a civil\n\npenalty of $10,000. In sum Plaintiff\u2019s NYLL claims exceed the amount in controversy limit for\n\n\n                                                  -3-\n\f              Case 6:24-cv-06473 Document 1 Filed 07/31/24 Page 4 of 13\n\n\n\n\nsubject matter jurisdiction.\n\n                                         THE PARTIES\n\nA.      Plaintiff\n\n        Joshua Christman\n\n        15.    Joshua Christman has been employed by Defendants as a Data Center Operator from\n\nJune 20, 2022 to June 5, 2024. Mr. Christman job duties include maintaining and installing servers,\n\nrunning ports, installing shelves, minor repairs and constructions, moving supplies and driving a\n\nforklift.\n\n        16.    During his employment, Mr. Christman worked for Defendants at the Lake Mariner\n\nlocation in Barker, New York.\n\n        17.    During his employment, over twenty-five percent of Mr. Christman\u2019s duties were\n\nphysical tasks, including but not limited to: performing field repairs of electrical equipment and\n\nmaintenance on buildings and equipment.\n\n        18.    Despite regularly spending more than twenty-five percent of his shift performing\n\nthese physical tasks, Mr. Christman has been compensated by Defendants on a bi-weekly basis.\n\n        19.    For example, for the week beginning May 13, 2024 and ending May 26, 2024, Mr.\n\nChristman was paid his lawfully earned wages on May 31, 2024. See Exhibit A, Christman\n\nPaystub.\n\n        20.    In this regard, Defendants failed to Mr. Christman his wages earned from May 13,\n\n2024 through May 19, 2024 by May 26, 2024 as required by NYLL \u00a7 191 (1)(a).\n\nB.     Class Members\n\n        21.    As described in more detail below, Class Members, Plaintiffs or Manual Workers\n\nare those employees of Defendant from July 31, 2018 to the date of judgment who are similarly\n\n\n\n                                               -4-\n\f               Case 6:24-cv-06473 Document 1 Filed 07/31/24 Page 5 of 13\n\n\n\n\nsituated to the Named Plaintiff in that they were compensated on a bi-weekly basis and worked for\n\nDefendants in its location in New York State. Consequently, the amount in controversy in this\n\nmatter exceeds $75,000 exclusive of interests and costs.\n\nC.       Defendants\n\n         22.    At all times relevant hereto, Plaintiff was an \u201cemployee\u201d of Defendants as defined\n\nby the NYLL, \u00a7 651.\n\n         23.    At all times relevant hereto, Defendants are \u201cemployer[s]\u201d as defined in the NYLL,\n\n\u00a7 651.\n\n         TeraWulf Inc.\n\n         24.    Defendant TeraWulf is a foreign business corporation organized and existing under\n\nthe laws of Delaware.\n\n         25.    Defendant TeraWulf\u2019s principal executive office is located, Easton, Maryland.\n\n         26.    Defendant TeraWulf is a publicly traded corporation that owns and operates a bit\n\ncoin mining operations including the Lake Mariner location in Barker, New York where Plaintiff\n\nworked.\n\n         27.    Defendant TeraWulf controls and owns Beowulf as detailed in its Securities\n\nExchange Commission (\u201cSEC\u201d) filing Form 10-K. Specifically, Paul Prager, Chief Executive\n\nOfficer (\u201cCEO\u201d) and chairman of the board of directors of TeraWulf controls Beowulf as detailed\n\nin the SEC Form 10-K\n\n         28.    Defendant\u2019s TeraWulf\u2019s employees are engaged in interstate commerce, and their\n\nannual gross volume of sales made or business done exceeds $500,000, exclusive of excise taxes.\n\n         29.    During the course of his employment by Defendant TeraWulf, Plaintiff handled\n\ngoods, including equipment and products that moved in interstate commerce.\n\n\n\n                                                -5-\n\f              Case 6:24-cv-06473 Document 1 Filed 07/31/24 Page 6 of 13\n\n\n\n\n        Beowulf E&D (NY), Inc.\n\n        30.    Defendant Beowulf is foreign business corporation organized and existing under the\n\nlaws of Delaware.\n\n        31.    Defendant Beowulf\u2019s principal executive office is located in Easton, Maryland.\n\n        32.    Plaintiff\u2019s paystub listed Beowulf as his employer. See Exhibit A, Christman\n\nPaystub.\n\n        Defendants Constitute Joint Employers\n\n        33.    Defendants possess or possessed substantial control over Plaintiffs working\n\nconditions, and over the policies and practices with respect to the employment and compensation\n\nof Plaintiffs, and all similarly situated individuals referred herein.\n\n        34.    Defendants employ or employed Plaintiff and those similarly situated and are or\n\nwere Plaintiffs\u2019 employers within the meaning of 29 U.S.C. 201 et seq. and the NYLL.\n\n        35.    As detailed in the SEC Form 10-K Beowulf is owned and controlled by TeraWulf\n\nand pursuant to service agreements performs bit coin mining services at the Lake Mariner bit\n\nmining facility where Plaintiff worked.\n\n        36.    Upon information and belief, Defendant TeraWulf has the right to inspect the\n\nfacilities and operations at Lake Mariner and the right to audit all records.\n\n        37.    Upon information and belief, Defendant TeraWulf has the authority to control,\n\ndirectly or indirectly, the timekeeping and payroll practices of Beowulf Defendants.\n\n        38.    Upon information and belief, Defendant TeraWulf knew or should have known of,\n\nand had the authority to exercise control over, the accuracy of records concerning the hours and\n\nwages of Plaintiffs and similarly situated employees through the monitoring of Beowulf.\n\n        39.    TeraWulf Defendant could have terminated the service agreements of Beowulf\n\n\n\n                                                 -6-\n\f             Case 6:24-cv-06473 Document 1 Filed 07/31/24 Page 7 of 13\n\n\n\n\nDefendant and caused Beowul Defendant to cease operations at the Lake Mariner facility under\n\ncertain circumstances, including in the event of violations of the law. Thus, upon information and\n\nbelief, TeraWulf Defendant has the authority to stop violations of the labor law and, ultimately, to\n\ncontrol the employment of Plaintiffs, including, but not limited to, causing the termination of their\n\nemployment. Moreover, TeraWulf Defendant has had the power to induce compliance with\n\napplicable wage and hour law by threatening to terminate a service agreement with Beowulf\n\nDefendant.\n\n       40.    Upon information and belief, TeraWulf Defendant\u2019s profits and financial well-being\n\ndepend upon the success of the Beowulf Defendant directly profited from the unlawful wage and\n\nhour practices at the Lake Mariner location.\n\n       41.    TeraWulf Defendant has the power to stop the unlawful wage and hours practices at\n\nits Beowulf Defendant but have not done so.\n\n                       NEW YORK CLASS ACTION ALLEGATIONS\n\n       42.    The NYLL claim is properly maintainable as a class action under Federal Rule of\n\nCivil Procedure 23 (\u201cRule 23\u201d).\n\n       43.    The Rule 23 class consists of the following:\n\n               All persons who work or have worked as Manual Workers for\n               Defendants in New York between July 31, 2018 and the date\n               of final judgment in this matter (the \u201cNew York Class\u201d).\n\n       44.    The number of putative class members is over 40.\n\n       45.    Plaintiff\u2019s claims are typical of the those claims that could be alleged by any member\n\nof the New York Class, and the relief sought is typical of the relief which would be sought by each\n\nmember of the New York Class in separate actions.\n\n       46.    Common issue of law and fact predominate in this action because resolution of\n\n\n\n                                                -7-\n\f                    Case 6:24-cv-06473 Document 1 Filed 07/31/24 Page 8 of 13\n\n\n\n\nwhich to resolve a significant aspect of this litigation in one stroke including, but are not limited\n\nto, the following:\n\n                \uf0b7    Whether Defendants compensated Plaintiff and the New York Class on a timely\n                     basis.\n\n          47.        Plaintiff and the New York Class have all been injured in that they have been\n\ncompensated in an untimely manner due to Defendants\u2019 common policies, practices and patterns\n\nof conduct. Defendants\u2019 corporate-wide policies and practices affected everyone in the New York\n\nClass similarly, and Defendants benefitted from the same type of unfair and/or wrongful acts as to\n\neach member of the New York Class.\n\n          48.        Further, there are no known conflicts of interest between the Plaintiff and the New\n\nYork Class Members. Moreover, the Plaintiff will adequately represent the interests of the class\n\nmembers because he is similarly situated to the New York Class members.\n\n          49.        Class Counsel, Cordello Law PLLC is qualified and able to litigate the Plaintiffs\u2019\n\nclaims.\n\n          50.        The Class Counsel concentrates its practice in employment litigation and is\n\nexperienced in class actions arising under wage and hour laws.\n\n          51.        A class action is superior to other available methods for the fair and efficient\n\nadjudication of the controversy \u2013 particularly in the context of wage and hour litigation where\n\nindividual class members lack the financial resources to vigorously prosecute a lawsuit against a\n\ncorporate defendant. Class action treatment will permit a large number of similar persons to\n\nprosecute their common claims in a single forum simultaneously, efficiently, and without the\n\nunnecessary duplication of efforts and expense that numerous individual actions engender.\n\n                               NEW YORK LABOR LAW \u00a7 740 ALLEGATIONS\n\n          52.        As discussed further herein, Defendants summarily terminated Mr. Christman based\n\n                                                     -8-\n\f                Case 6:24-cv-06473 Document 1 Filed 07/31/24 Page 9 of 13\n\n\n\n\nupon his objections to Defendants\u2019 unsafe work conditions which reasonable believed posed a\n\nspecific and substantial danger to public safety and health.\n\nMr. Christman Objects to Defendants\u2019 Unsafe Work Conditions\n\n          53.    On December 28, 2023 and then again on January 24, 2024 Mr. Christman met with\n\nDefendants\u2019 Plant Manager Dan Heidmann to discuss his workplace safety concerns and threats\n\nof violence made by his direct supervisor Data Center Supervisor Greg Miller. For example, Mr.\n\nChristman complained about significant Occupational Safety Health Administration (\u201cOSHA\u201d)\n\nviolations including the lack of training for operating Defendants\u2019 30-foot bucket truck, having\n\nemployees jump in dumpsters to pack down garbage, as well as Supervisor Miller\u2019s threats of\n\nphysical violence towards employees.\n\n          54.    In May 2024 Supervisor Miller confronted Plaintiff Christman that he should not be\n\ndocumenting safety violations for OSHA. Mr. Christman denied that he was bringing safety issues\n\nto OSHA and instead maintained that he was documenting them for the Defendants\u2019 safety\n\nmeeting. Supervisor Miller threatened to \u201cbeat up\u201d Mr. Christman and \u201ckick his ass\u201d and \u201ctake\n\nhim out to the stones\u201d if he disclosed safety violations to OSHA. Shortly thereafter Mr. Christman\n\nwas terminated.\n\nDefendants Terminate Mr. Christman\n\n          55.    On June 5, 2024 Mr. Christman was terminated based on multiple violations of\n\ncompany policies, specifically unauthorized recording of a meeting on May 30, 2024.\n\n          56.    Mr. Christman\u2019s termination was in retaliation for what Defendants knew or\n\nbelieved to be his protected activity of objecting to Defendants\u2019 workplace safety violations which\n\nMr. Christman reasonably believed posed a substantial and specific danger to public health and\n\nsafety.\n\n\n\n                                                 -9-\n\f               Case 6:24-cv-06473 Document 1 Filed 07/31/24 Page 10 of 13\n\n\n\n\nMr. Christman Engaged in Protected Activity Under N.Y. Labor Law \u00a7 740 By Objecting to\nDefendants\u2019 Unsafe and Dangerous Practices\n\n         57.    Mr. Christman objected to Defendants\u2019 unsafe work conditions and threats of\n\nphysical violence by his direct supervisor which Mr. Christman reasonably believed posed a\n\nsubstantial and specific danger to public health or safety.\n\n         58.    Mr. Christman afforded Defendants a reasonable opportunity to correct these unsafe\n\ncondition, but Defendants failed to do so.\n\n         59.    By raising these concerns, Mr. Christman engaged in protected activity under NYLL\n\n\u00a7 740.\n\nDefendants Improperly Terminated Mr. Christman\n\n         60.     Defendants\u2019 termination of Mr. Christman violates NYLL \u00a7 740. Mr. Christman\n\nreceived an average rating on his annual performance evaluations and standard bonuses and never\n\nreceived any written disciplinary warnings during his tenure with Defendants. However, after he\n\nobjected to Defendants\u2019 unsafe work conditions and threats of physical violence he was summarily\n\nterminated. Moreover, the timing of his termination indicates Defendants retaliated against Mr.\n\nChristman because he continued to disclose what he believed to be a substantial and specific\n\ndanger to the public health and safety.\n\n         61.    Defendants for the first time when it terminated Mr. Christman informed him that\n\nhe had been issued a written disciplinary warning. However, Mr. Christman never received this\n\nwritten disciplinary warning and requested a copy of the written warning. To date Defendants\n\nhave failed to produce this written warning.\n\n         62.    Thus, Defendants improperly discharged and retaliated against Mr. Christman\n\nbecause of the lawful acts he had taken under NYLL \u00a7\u00a7 740.\n\n                                               COUNT I\n\n\n                                               - 10 -\n\f             Case 6:24-cv-06473 Document 1 Filed 07/31/24 Page 11 of 13\n\n\n\n\n               Violation of the New York Labor Law \u00a7 191 - Frequency of Payments\n\n       63.    Defendants are an employer that is subject to and must abide by the frequency of\n\npayments provisions of the NYLL.\n\n       64.    Defendants paid Plaintiff and the New York Class on a biweekly basis.\n\n       65.    In the last six years, Plaintiff and the New York Class spent more than 25% of their\n\nworking time performing work tasks of a physical nature.\n\n       66.    Plaintiffs and the New York Rule Class are \u201cmanual workers\u201d within the meaning\n\nof NYLL \u00a7 191(1)(a)(i).\n\n       67.    By paying Plaintiff and the New York Class on a biweekly basis, Defendants paid\n\nPlaintiff and the New York Class their wages due \u201clater than seven calendar days after the end of\n\nthe week in which the wages were earned.\u201d N.Y. Lab. L. \u00a7191(1)(a).        Defendants violated the\n\nNYLL by failing to compensate Plaintiff and the New York Class consistent with the minimum\n\nwage provisions.\n\n       68.    Because Defendants failed to pay Plaintiff and the New York Class on a weekly\n\nbasis, they are entitled to recover liquidated damages equal to the full amount of their wages paid\n\nlater than seven days after the end of a workweek in each biweekly period within the six years\n\nprior to the filing of this Complaint.\n\n                                                  COUNT II\n\n                         Violation of New York Labor Law \u00a7 740 - Retaliation\n\n       69.    Mr. Christman objected to Defendants\u2019 unsafe work conditions and OSHA\n\nviolations threats of physical violence which he reasonably believed posed a substantial and\n\nspecific danger to the public health or safety.\n\n       70.    Mr. Christman objected to, refused to participate in and or/threatened to disclose\n\n\n\n                                                  - 11 -\n\f             Case 6:24-cv-06473 Document 1 Filed 07/31/24 Page 12 of 13\n\n\n\n\nDefendants\u2019 unsafe activities.\n\n       71.    Mr. Christman afforded Defendants a reasonable opportunity to correct the danger\n\nto public health or safety, but Defendants failed and refused to do so.\n\n       72.    In retaliation for Mr. Christman disclosures and objections, Defendants retaliated\n\nagainst him by terminating him in violation of New York Labor Law \u00a7 740.\n\n                                      PRAYER FOR RELIEF\n\n       WHEREFORE, Plaintiff and the New York Class pray for judgment against Defendants as\nfollows:\n\n               (a)     Certification of this case as a class action pursuant to Rule 23 of the Federal\n                       Rules of Civil Procedure;\n\n               (b)     Designation of Plaintiff as representative of the Rule 23 Class and counsel\n                       of record as Class Counsel;\n\n               (c)     An order preliminarily and permanently restraining Defendants from\n                       engaging in the aforementioned pay violation;\n\n               (d)     Liquidated damages permitted by law pursuant to the NYLL;\n\n               (e)     An award of reasonable attorneys\u2019 fees and costs;\n\n               (f)     An award of pre- and post-judgment interest;\n\n               (g)     An injunction reinstating Plaintiff to his prior position with the same\n                       seniority status, fringe benefits, and other terms and conditions of\n                       employment that Plaintiff would have had but for defendant\u2019s retaliatory\n                       acts;\n\n               (h)     An injunction permanently restraining Defendants from engaging in the\n                       aforementioned retaliation;\n\n               (i)     A declaration that Defendants\u2019 conduct complained of herein violated\n                       Plaintiff\u2019s rights as secured by the NYLL;\n\n               (j)     An award to Plaintiff in an amount equal to the amount of back pay,\n                       including lost fringe benefits and bonuses, with interest, that Plaintiff would\n                       have earned but for Defendants\u2019 retaliatory acts;\n\n               (k)     An award to Plaintiff of all compensatory and consequential damages,\n                       including the value of Plaintiff\u2019s unpaid wages and bonuses;\n                                               - 12 -\n\f           Case 6:24-cv-06473 Document 1 Filed 07/31/24 Page 13 of 13\n\n\n\n\n              (l)      An award to Plaintiff of the actual losses sustained by Plaintiff as a direct\n                       result of Defendants\u2019 violations;\n\n              (m)      An award to Plaintiff of front pay, punitive damages and a civil penalty of\n                       $10,000; and\n\n              (n)      Such other and further legal or equitable relief as this Court deems to be just\n                       and appropriate.\n\n\n\n                                        JURY DEMAND\n\n       Plaintiff demands a jury to hear and decide all issues of fact in accordance with Federal\n\nRule of Civil Procedure 38(b).\n\nDated: July 31, 2024\n\n                                                        CORDELLO LAW PLLC\n\n                                                By:     /s/ Justin M. Cordello_____________\n                                                        Justin M. Cordello, Esq.\n                                                        Attorney for Plaintiff\n                                                        200 Anderson Avenue\n                                                        Rochester, New York 14607\n                                                        Telephone: (585) 967-7707\n                                                        justin@cordellolaw.com\n\n\n\n\n                                               - 13 -\n\f","ocr_status":2,"date_upload":"2024-08-01T07:58:05.791757-07:00","document_number":"1","attachment_number":null,"pacer_doc_id":"12906429807","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Complaint","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/407338198/","id":407338198,"tags":[],"absolute_url":"/docket/69005981/1/1/christman-v-terawulf-inc/","date_created":"2024-08-01T07:57:57.571059-07:00","date_modified":"2024-08-01T07:57:57.571066-07:00","sha1":"","page_count":2,"file_size":222184,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"1","attachment_number":1,"pacer_doc_id":"12906429808","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit A","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/407338199/","id":407338199,"tags":[],"absolute_url":"/docket/69005981/1/2/christman-v-terawulf-inc/","date_created":"2024-08-01T07:57:57.602543-07:00","date_modified":"2024-08-01T07:57:57.602552-07:00","sha1":"","page_count":1,"file_size":239917,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"1","attachment_number":2,"pacer_doc_id":"12906429809","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Civil Cover Sheet","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/407338200/","id":407338200,"tags":[],"absolute_url":"/docket/69005981/1/3/christman-v-terawulf-inc/","date_created":"2024-08-01T07:57:57.625175-07:00","date_modified":"2024-08-01T07:57:57.625182-07:00","sha1":"","page_count":2,"file_size":57257,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"1","attachment_number":3,"pacer_doc_id":"12906429810","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Summons TeraWulf","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/407338201/","id":407338201,"tags":[],"absolute_url":"/docket/69005981/1/4/christman-v-terawulf-inc/","date_created":"2024-08-01T07:57:57.648461-07:00","date_modified":"2024-08-01T07:57:57.648470-07:00","sha1":"","page_count":2,"file_size":57274,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"1","attachment_number":4,"pacer_doc_id":"12906429811","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Summons Beowulf","acms_document_guid":""}],"date_created":"2024-08-01T07:57:55.286655-07:00","date_modified":"2024-08-01T07:57:55.289897-07:00","date_filed":"2024-07-31","time_filed":null,"entry_number":1,"recap_sequence_number":"2024-07-31.001","pacer_sequence_number":4,"description":"","tags":[]}],"entries_total":"https://www.courtlistener.com/api/rest/v4/docket-entries/?count=on&docket=69005981&page_size=40"}